Thursday, July 23, 2015

It's Hard to Even Comment: The Vermont Energy Plan

Comments due tomorrow

In yesterday's post I wrote that the Vermont Energy Plan is Basically Unworkable.  It's not only unworkable, it is almost impossible to comment on it.

Public comments on this update to Vermont's Comprehensive Energy Plan are due to the Vermont Public Service Department (PSD) by tomorrow.  In my blog post, I encourage people to comment.  I shouldn't ask people to do what I haven't done myself.  I had no idea what I was getting into, when I decided to comment.

Commenting is difficult

For this round of comments, the schedule is very compressed. (There will be another comment period in the fall.)  The PSD set invitational meetings in late June, has public meetings in July, and insists that all comments are submitted by late July. This is despite the fact there are  hundreds of pages of reading material on these subjects.

There are two ways that PSD wants you to send comments, as listed in the page Update to the Comprehensive Energy Plan. To quote the PSD page:

"Written comments are welcome at ( by July 24, 2015.
You may also provide comment in response to specific questions raised by the Department at ( by July 24, 2015."

Opening the Forms

So I followed those links.

The link ending OC is the Open Comment survey form.  The link ending FQ is Framing Questions survey form. These forms are different, though related.  Each form is nine pages long.  Both forms have  from one to several questions per page. Though, in fairness, the first two pages have no questions, just directions and a place to put your name and so forth. After the initial pages, here's how the forms are:

OC. The pages of the OC form aren't really questions: They are  topic areas in which you can comment.
For example, under Transportation in the OC form, you can comment on
Freight Heavy Duty Vehicles
Zero Emission Vehicle Action Plan

Or (under Energy Financing in the OC form)
Energy Financing

FQ:  The FQ form asks more directed questions.  For example, the first real question (not about filling out your name) asks:
What areas of the 2011 CEP need updates? It includes links to all the volumes of the 2011 CEP.

The next question links to a dozen recent PSD reports. It asks how these reports and processes should be incorporated into the new CEP.

Later questions include this one:
9. How should the 2015 CEP update address the use of natural gas? How should the plan differentiate between policies regarding the use of this fossil fuel and policies regarding construction of pipeline infrastructure that can carry both fossil natural gas and other gaseous fuels such as renewable natural gas?

A New Job?

Clearly, commenting on these forms could be a full time job.  I don't have full time for this, and I suspect my readers don't have full time for it either. So, I am back to square one.  I shouldn't ask people to do what I haven't done.  What am I going to do?

On page 8 there's a space to make a positive comment about nuclear energy, which I did.  On page 9, I was a bit crabby. I said the Comprehensive Plan is a slogan, not a plan.  I also suggested the PSD stop wasting taxpayer money on writing expensive reports.

In the FQ document, the first question is about "what parts of the 2011 CEP plan need to be updated."  I suggested that, since we are making very little energy instate, we should plan to buy more energy from Seabrook and Millstone.

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